Ohio Civil Rights Commission v. Dayton Christian Schools, Inc.

477 U.S. 619 (1986)

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Nature of the Case

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Facts

P was a teacher at Dayton Christian Schools (D). D was a private non-profit school that provided elementary and secondary education and required that all its employees subscribe to religious beliefs, including the belief of resolution of problems through the biblical chain of command. P was under contract with D, and part of that contract was a dispute resolution process based not on the court system but God’s chain of command. P got pregnant and was told her employment contract with D would not be renewed because P should stay at home with her preschool children. P got an attorney and threatened litigation. D then retracted its earlier decision but then terminated her for violation of her contract to resolve disputes through the biblical chain of command. P then filed a charge with the Ohio Civil Rights Commission for unlawful sexual discrimination. The Commission initiated administrative proceedings against D who answered the complaint based on First Amendment rights and that this assertion prevented the Commission from having jurisdiction. While the administrative proceedings were ongoing, D and others filed an action in District Court seeking an injunction against the state proceedings. The District Court refused to issue an injunction. The Court of Appeals reversed holding that the Commission’s exercise of jurisdiction would violate both the Free Exercise Clause and the Establishment Clause. The Supreme Court granted certiorari.